More often than not, the supply of certified wood on the market is insufficient for the production of goods that consist exclusively of it. Certified wood products may therefore also contain non-certified wood, to which a less stringent set of criteria is applied. These must, however, be applied to all non-certified wood that a buyer of certified wood purchases.

The rules of the FSC forest certification system state that companies purchasing wood are
themselves responsible for assessing the risks related to the procurement of non-certified wood,
in other words, controlled wood, and the management of these risks. The international rules
used for this have changed recently: according to the new rules, risks must be assessed
separately for each country, rather than each company carrying out its own risk assessment.
The risk assessment for Finland is currently under way. The result of this work will be significant
for all Finnish forest owners.
Although the area of FSC-certified forests is clearly below ten per cent of the commercial forests

in Finland, the rules for controlled wood apply to all non-FSC-certified wood purchased by FSC-
certified wood buyers in Finland – even when it is certified under the other forest certification

system, the PEFC.
The acceptability of FSC-controlled wood is evaluated in five categories. Firstly, the wood may
not be illegally procured, and secondly, it may not originate from areas where traditional or civil
rights are violated.
Thirdly, the wood may not originate from forests where wood procurement threatens what are
called high conservation values (HCV). Fourthly, that wood may not originate from areas where
land use has been changed to, for example, tree plantations.
And fifthly, the wood may not be genetically modified.
Either manage the risks or stop buying the wood
The risk in each category is assessed for the whole country, for parts of it or, for example, for
different forest owner groups. If a risk is identified, the company purchasing the wood must be able to
show how it manages the risk in order to comply with the requirements set for controlled wood
by the FSC.

“If it is the case that you cannot mitigate the risk, you may not use the wood to produce FSC-
certified products,” says Karoliina Niemi, Manager, EU forest affairs, at the Finnish Forest

Industries Federation.
The main principle is that the risk assessment is carried out by national actors in each country. If

this proves impossible, the assessment is carried out by FSC International.
Efforts were made in Finland to carry out the national risk assessment, but after years of
negotiations, the process was halted with no results. “The Board of FSC Finland decided to
have FSC International carry out the work,” says Anniina Kostilainen, General Secretary of
FSC Finland.
The FSC chose the consulting company NEPCon for the work, with the help of the Finnish company
Tapio. In a stakeholder consultation in April, Ditte Steffensen from NEPCon said that even
before this, the risk in Finland had been assessed as low in the categories concerning illegal
wood, traditional rights and genetically modified wood.
Work on the categories of HCV forests and land use change is continuing.
According to Anniina Kostilainen, General Secretary of FSC Finland, the FSC rules for controlled wood
deal only with wood that is not FSC certified. Photo: Erkki Oksanen
FSC calls its own rules into question
In HCV forests, the matter assessed is whether or not forestry activities threaten conservation
values. If the threat is temporary, exceptional or limited in impact, the risk is considered to be
low.
According to Steffensen, in Finnish commercial forests there exists a risk related to habitats
requiring special protection as defined by the FSC itself. The reasoning behind this is that the
mapping of all such habitats is not complete. The FSC list of these habitats is long.
According to Steffensen, forestry also poses a threat to forests in the Sámi Homeland, as well as to
forest areas defined as intact (IFL areas) by environmental organisations in Lapland and the
Kuusamo municipality. However, only about one per cent of the IFL areas in Finland are outside
protection.
As regards the category of land use changes, Finland is defined as a risk area for the time
being. Although it is true that a small share of forests in Finland is repurposed for other uses each
year, Niemi fails to understand FSC International’s approach in this, as it runs partly against
its own principles.
The FSC definition is that a clear-cut and regenerated boreal forest is not a plantation, so
establishing a forest in this way does not constitute a land use change. “Nevertheless, this case is mentioned in
the risk assessment concerning land use changes. This is highly illogical and must be looked
into,” says Niemi.
The FSC relies on data from Global Forest Watch, stating that each year in Finland, an average
total of 160,000 hectares of natural forests are converted to other land uses. Niemi would like to
know the basis for this figure.
“Just the regeneration fellings in our commercial forests only amount to 130,000 hectares
annually,” says Niemi.
Criteria will be finalised during autumn
According to Lauri Kajander, representing the environmental organisation Luonto-Liitto (Nature

League) and speaking at the consultation in April, preparing the criteria has been complicated
because Finnish forestry does not even meet the FSC requirements for controlled wood.
Niemi finds it a strange situation: there are efforts to make some of the criteria for controlled
wood stricter than the certification standard itself.
The risk assessment will be completed during the autumn. After that, wood purchasers with
FSC certification will have six months to develop tools to manage the risks identified. According
to Kostilainen, it is very important that the risk management tools are practical and easy to audit.
The PEFC certification system also has a corresponding system: purchasing wood from
controversial sources is prohibited. If a timber lot may entail significant risks, the buyer must
carry out a risk assessment before the purchase.
The PEFC does, however, allow the purchase of such wood if it is FSC-certified, although the FSC does
not reciprocate for the PEFC.